New Mexico v. Baca
Annotate this CaseDefendant Abraham Baca was arrested by Sergeant Martin Trujillo for aggravated DWI and driving left of center of a roadway. The State filed a criminal complaint against Defendant in Magistrate Court. While the magistrate court proceedings were not recorded, what did appear in the record was that on the day of trial, the magistrate judge entered a written order dismissing the case with prejudice upon motion of the defense. The Trial Order was entered on a standardized court form that contained, among other options, fields for recording the magistrate's determination of guilty or not guilty, but these fields were left completely blank and instead the order recited that the cause was "dismissed with prejudice." The State appealed to the district court. While that appeal was pending, the magistrate court sua sponte entered a new, amended signed order in its own files, stating: "A motion was made by defense attorney Ben Ortega to suppress the testimony of Sergeant Martin Trujillo for violation of NMRA 6-506-A(C)(D). Sergeant Martin Trujillo was the arresting Officer. A second motion was made by defense attorney Ben Ortega for a directed verdict of not guilty due to insufficient evidence to proceed. Motion to suppress and directed verdict of not guilty were granted. The Defendant is therefore acquitted." Once the amended magistrate court order was filed, defense counsel moved to dismiss the State's appeal at the district court. The district court found that the magistrate judge's premature termination of the case had been a dismissal to sanction the State's filing of a nonconforming criminal complaint, rather than an acquittal on the merits. Concluding that the State's appeal did not result in double jeopardy, the district court accordingly denied Defendant's motion to dismiss the appeal. Defendant appealed the district court's order denying his motion to dismiss to the Court of Appeals. The Court of Appeals reversed the district court, concluding that because "the magistrate court's dismissal constituted an acquittal and, therefore, the State was barred from appealing," it was inappropriate to address "whether . . .Judge Naranjo's ruling suppressing Sergeant Trujillo's testimony was erroneous." After review, the Supreme Court reversed, finding that the district court did not err in ruling the state was not constitutionally barred from further prosecution. The magistrate court's termination of defendant's trial before the State had completed presenting its evidence in its case in chief was a procedural dismissal rather than an acquittal on the merits.
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